ANTI-SLAVERY AND ANTI-TRAFFICKING STATEMENT 2024

Introduction

MeGirlNextDoor owns and operates the website Megirlnextdoor (www.megirlnextdoor.com) ("Megirlnextdoor" or the "Company"), a subscription-based social platform that enhances creator and fan interactions. Our mission is to empower content creators from all backgrounds to fully realize their potential, in line with our values and objectives.

Megirlnextdoor is firmly committed to combating modern slavery and human trafficking. We do not tolerate these heinous activities on our platform, in our partnerships, or within our supply chain. This statement is made in accordance with our company values and legal requirements such as the UK Modern Slavery Act, the Australian Modern Slavery Act, and the California Transparency in Supply Chains Act. It outlines the steps taken by Megirlnextdoor to prevent modern slavery and human trafficking in our business operations, partnerships, and supply chains.

Our Commitment

Modern slavery is a violation of fundamental human rights and includes various exploitative practices like slavery, servitude, forced labor, and human trafficking. Megirlnextdoor stands against all forms of modern slavery and human trafficking, actively working to identify and mitigate risks in our business dealings and relationships. We commit to treating all employees, partners, and vendors with respect and dignity, ensuring safe working conditions, and conducting ethical and environmentally responsible operations.

Steps Taken to Prevent, Detect, and Report Modern Slavery and Human Trafficking Risks

In this financial period, we have:

- Rolled out mandatory training on modern slavery and human trafficking for all employees.

- Implemented company-wide policies and procedures promoting ethical conduct.

- Reviewed our supply chains to identify and mitigate risks associated with modern slavery and human trafficking.

- Enhanced our content moderation approach by hiring additional specialist resources.

- Appointed an independent monitor to review our safety controls and compliance program.

- Increased engagement with third-party organizations fighting modern slavery and human trafficking.

Our Policies

Megirlnextdoor is dedicated to taking all reasonable and appropriate steps to prevent modern slavery and human trafficking activities on our platform, within our business, and across our supply chain. Our Code of Conduct & Business Ethics outlines our expectation that all employees act with integrity and comply with applicable laws, including those related to modern slavery and human trafficking. This code is also shared with key suppliers and contractors.

Our Terms of Service and Acceptable Use Policy specifically prohibit the uploading, posting, displaying, or publishing of content that includes individuals without their written consent or refers to escort services, sex trafficking, or prostitution.

Risk Assessment

We continuously assess risks related to modern slavery and human trafficking by identifying and analyzing higher-risk areas within our business. This assessment is based on external reports, standards, and sector risk profiles, and we adjust our processes and controls as necessary based on changing risks.

Direct Business Operations

The risk of modern slavery and human trafficking in our direct business operations is relatively low, as our workforce primarily consists of professionally qualified personnel. However, we remain vigilant, especially regarding contractors outside the United Kingdom and the United States, and ensure that all employees are aware of the risks and our stance on these issues, thereby enabling them to report any suspected instances.

Platform and Supply Chain

- Creator Content: Social media platforms inherently face risks of exploitative content uploads. We enforce stringent moderation practices to mitigate these risks.

- Contractors and Third Parties: We use contractors and third-party suppliers for user verification and content moderation processes. These parties are bound by our policies and relevant laws.

- Merchandise: The garment industry is known for higher exploitation risks. We ensure our promotional merchandise suppliers adhere to stringent labor and ethical standards.

Risk Mitigation Efforts

We are committed to reporting on key actions taken to mitigate risks, including:

- Creator Verification: We thoroughly verify identity and payment details for each creator account to ensure legitimacy. Additional safeguards are applied in high-risk jurisdictions.

- Content Moderation: We monitor all media uploaded to the platform and enforce compliance with our terms and policies. Our content moderators are trained to identify and report any suspected modern slavery or human trafficking.

- Contractor or Agency Staff: Contractual obligations ensure that agencies and temporary staff comply with our policies. Annual training on modern slavery and human trafficking is mandatory.

- Merchandise: We ensure commercial agreements with manufacturers align with our anti-slavery and ethics policies.

- Community Reporting: We provide mechanisms for users and the wider community to report concerns. Reports related to immediate physical danger are escalated to law enforcement.

- Assist Law Enforcement: We suspend accounts and report identified content related to modern slavery to law enforcement and NGOs.

- Investments and Partnerships: We invest in technologies to detect exploitative content and collaborate with NGOs and charities to safeguard our users.

Transparency & Reporting

Megirlnextdoor is dedicated to building the safest social media platform. We publish data verifying our anti-slavery steps in our Transparency Reports and have an independent third-party monitor to audit our safety controls and compliance program.

Reporting Mechanisms

We encourage transparency, honesty, and accountability. Employees can report concerns or wrongdoings, including human rights violations, by emailing compliance@megirlnextdoor.com. Reports are investigated, and appropriate actions, including termination, are taken if necessary.

Ongoing Commitment to Improvement

Combating modern slavery and human trafficking is an ongoing effort. We will:

- Continuously assess risks within our business and supply chain.

- Mitigate identified risks.

- Protect whistleblowers.

- Stay updated with legal changes.

- Monitor potential risks and implement solutions.

Responsibility for this Statement

Our Executive Leadership is responsible for ensuring compliance with this statement. Management must ensure their teams understand and adhere to our anti-slavery policies. Our Legal team oversees the principles in this statement and ensures the effectiveness of our internal control systems.

This statement has been approved by the Board of MeGirlNextDoor.

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We are committed to keeping Megirlnextdoor safe and free from exploitation. Thank you for supporting our efforts to combat modern slavery and human trafficking.